Interpretation Response #15-0141 ([Daniels Training Service] [Mr. Daniel Stoehr])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Daniels Training Service
Individual Name: Mr. Daniel Stoehr
Location State: IL Country: US
View the Interpretation Document
Response text:
September 21, 2015
Mr. Daniel Stoehr
Daniels Training Service
P.O. Box 1232
Freeport, IL 61032
Ref. No. 15-0141
Dear Mr. Stoehr:
This responds to your July 7, 2015 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the incident reporting requirements for excepted packages of Class 7 (radioactive) material. Specifically, you suggest that there is an error in § 173.422(c), which incorrectly references § 175.700(b) instead of § 175.705.
As currently drafted, § 173.422(c) requires excepted packages that are leaking or from which a release has occurred to comply with the reporting requirements in §§ 174.750, 175.700(b), or 176.710 dependent on the mode of transportation. In a final rule published under Docket Number RSPA-02-11654 (HM-228) [71 FR 14586], the reporting requirements for Class 7 (radioactive) material transported by air were moved from § 175.700(b) to § 175.705 without a corresponding revision to § 173.422(c). We will correct this reference in a future rulemaking. In the interim, we recommend that incidents involving excepted packages of Class 7 (radioactive) material transported via air comply with the requirements prescribed in § 175.705 since the present § 175.700(b) is not relevant to incident reporting.
I hope this information is helpful.
Sincerely,
Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division
175.700(b), 175.705, 173.422(c), 174.750